We are writing to object in the strongest possible terms to the recommendation which comes before you tonight in Agenda Item 7A, which would allow commercial fitness or athletic activities in Palisades Park and other city parks.

As you know, The North of Montana Association has urged rejection of this idea in the past. So have both the Recreation and Parks Commission and the Landmarks Commission.

And now we have learned that the city staff has met and negotiated with the Fitness Trainers Coalition to arrive at this so-called compromise, but not with NOMA or the other above-named commissions.

To say that this is distressing is a vast understatement.

The city staff has failed to include in their talks the very organizations which represent the primary stakeholders here – the residents, voters and taxpayers of our city.

We ask you: How can such a recommendation go forward without the participation of the stakeholders? Why is the staff honoring the wishes of a small but vocal group of fitness or athletic trainers who are conducting profit-making business on City property?

We also have grave reservations about the application of this proposed staff recommendation with regard to other city parks. We would be prepared to discuss them with city representatives in the event that a genuine “negotiation” might ever take place.

Among our concerns are the following:

-- Designated areas – The designated areas as proposed put an unfair burden on the North of Montana neighborhood. This is unacceptable.

--Enforceability – We strongly question whether the City can and will enforce these regulations. What is the impact on staffing?

-- Size of classes -- 15 maximum. This is a large group. What is the justification for this number? Has this been driven by the trainer coalition?

--Weight of equipment -- 25 pounds max. What does this mean? 25 pounds per participant? Per class? A 25-pound weight is heavy and will damage turf. Please prohibit all equipment in all city parks, or substantially reduce the weight limit and clarify how that weight limit is determined. Again, Staff recommendation seems to be driven by the trainer coalition. And enforceability will always be an issue.

-- Time restrictions -- 6 am start time. This will place an undue burden of noise and congestion on designated areas that are adjacent to residential areas and apartments. This start time is clearly another response to trainers, not residents.

--Permit fees -- $100/year, 15% of gross receipts per quarter. This seems inadequate to cover the cost of repairing the damage that will surely result from intense park use. What is the justification for $100, vs. $200 or any other amount? What is the enforcement mechanism?

--Education -- Any proposal under discussion should include a requirement that trainers undergo an orientation with regard to the history and features of Palisades Park, emphasizing its importance as a Santa Monica Landmark and the need to protect the features and landscape of this world-class park.

--Anticipated revenue -- Staff's projected revenue source of $63,000 would hardly seem to cover the expenses that the City will incur for administration, enforcement and increased park maintenance for this new program. It is also astonishing to note that the $63,000 to the General Fund has already been included in the adopted 2013-2014 budget, even prior to the adoption of the Staff-recommended program.

In conclusion, we urge you to reject the proposal before you. Do not allow commercial trainers to operate in historic Palisades Park or nearby Goose Egg Park under any circumstances. If further consideration of this matter is merited as regards other city parks, the city must consult with the true stakeholders here: the residents.